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DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
SDGT-9966
OFFICE OF FOREIGN ASSETS CONTROL
BLOCKING MEMORANDUM
The Office of Foreign Assets Control (OFAC), pursuant to Executive Order 13224 of September 23, 2001 ("Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten to Commit, or Support Terrorism") (the "Order"), the International Emergency Economic Powers Act, (IEEPA), 50 U.S.C. §1701 et seq., and the Global Terrorism Sanctions Regulations, 31 C.F.R. Part 594, (the "Regulations"), determines that there is reason to believe that a Specially Designated Global Terrorist has an interest in the electronic funds transfer identified below. That transfer therefore is hereby blocked.
The details of the transaction are as follows:
Beneficiary Bank: National Bank for Foreign Economic Activity of Republic of Uzbekistan, (Swift NBFAUZ2X)
Beneficiary Name: Uzbekistan Airways
Beneficiary Account number [...
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1) This Blocking Memorandum relates to the litigation discussed in the comments to Case No. SDGT-2017-344570-1. It is notable, especially in the context of the litigation, for the likelihood that it represents a use of OFAC’s “blocking during the pendency of an investigation” authority that is not apparent from the regulations. More specifically, it appears as though the funds as issue were blocked pending a resolution of an investigation into whether a given entity qualifies as a SDGT, where the identity of the person under investigation was being kept secret pending the completion of the investigation. See additional commentary at section IV of General Note on the Blocking of Persons and Property Pending Investigation.